Article: Arkansas Supreme Court rules state law bad faith claim preempted by ERISA

ERISA preempts a state law claim for the bad faith denial of long- term disability benefits, the Arkansas Supreme Court has ruled.

The plaintiff was a pack-a-day smoker who worked as a maintenance laborer at a chemical company for over 20 years. He suffered two heart attacks, resulting in an angioplasty and cardiac catheterization.

The plaintiff did not return to work and drew disability benefits for nearly three years. But the benefits plan required him to see a physician regularly to remain eligible for long-term disability benefits.

The plan administrator requested that the plaintiff provide

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